A Georgian VASP budget now has three distinct regulatory components: the GEL 5,000 registration fee, service-based supervisory capital and the cost of building and maintaining a compliant operation. These amounts should never be presented as interchangeable.
Paid before registration; proof of payment is submitted with the registration documentation.
The applicable minimum depends on the registered services and must be maintained throughout operation.
Legal, corporate, AML, filing and regulatory-response work should be scoped against the actual project.
Translations, notarisation/legalisation, premises, people, software, providers, assurance and similar costs are not the NBG fee.
The filing itself includes a business plan with at least a three-year budget forecast and evidence of resources and procedures.
The GEL 5,000 fee is a registration fee, not a turnkey project price
Georgian law sets the VASP registration fee at GEL 5,000. The fee is paid before registration and the payment receipt is filed with the other prescribed documents. It does not purchase legal structuring, company preparation, ownership evidence, administrators, translations, premises, technology, providers, AML implementation or NBG-response work.
Minimum supervisory capital is determined by the service model
Since 27 August 2026, ordinary Georgian VASPs have been subject to a service-based minimum-capital regime. The amount is not a fee or project expense: it is regulatory capital that the VASP must maintain while carrying on its registered activities.
| Registered service | Minimum supervisory capital |
|---|---|
| Virtual-asset exchange and/or transfer | GEL 150,000 |
| Administration of a virtual-asset trading platform | GEL 350,000 |
| Other VASP services | GEL 250,000 |
Where a VASP provides several services, the highest applicable amount applies; the amounts are not added together. At least 75% of the minimum must consist of primary-capital elements. Stablecoin initial offerings remain subject to their separate prudential framework. Existing registered VASPs must meet the general minimum-capital requirement by 1 September 2027.
Build the budget in five layers
| Budget layer | Typical components |
|---|---|
| 1. Official / filing | GEL 5,000 registration fee and any other official charges that become applicable to a specific corporate/document process. |
| 2. Supervisory capital | GEL 150,000, GEL 250,000 or GEL 350,000, depending on the registered services, together with capital-eligibility, source and continuing-adequacy analysis. |
| 3. Professional implementation | Regulatory classification, corporate/governance work, application preparation, service schemes, AML/CFT, project coordination, regulatory correspondence and agreed specialist workstreams. |
| 4. Third-party readiness | Notary/translation/legalisation, premises, recruitment, systems, KYC/KYT/sanctions vendors, hosting/security, provider onboarding and independent assurance where selected. |
| 5. Ongoing operation | Management and staff, office, software/providers, compliance operations, capital monitoring, reporting, training, independent audit, penetration testing, incident response, change control and remediation after registration. |
What drives professional scope?
- Business model: exchange, custody, transfers, platform, lending, ICO or stablecoin-related work creates different evidence and control requirements.
- Ownership: multi-country groups, holding structures, significant owners and UBO evidence can materially change the document workstream.
- People: administrator availability, competence, local operating capacity and recruitment can be on the critical path.
- Channels: cash service, branches and kiosks add premises, surveillance and operating requirements.
- Technology: an existing production-grade platform requires different work from software that still needs product, monitoring, logging or demonstration functionality.
- Providers: banks, PSPs, custodians, liquidity venues, VASPs and screening/KYT systems introduce contracting, due diligence and integration dependencies.
- Readiness: a reconciled data room and tested system can reduce remediation compared with a project that starts from a pitch deck and generic policies.
Separate preparation from statutory review
The 60-calendar-day NBG decision period begins from the prescribed registration information/document set. It can stop while an NBG information, system-demonstration or office-access request is outstanding, and the rule permits a reasoned additional 60-day extension. The commercial project therefore needs its own pre-filing timeline and contingency rather than treating “60 days” as the total implementation duration.
Budget through the first supervisory cycle
The three-year plan should support the operating company after registration while preserving the required supervisory capital. A VASP needs sufficient people, systems, provider capacity, premises, compliance operations and management information to deliver the registered scheme. Underfunding the first months can create exactly the control weaknesses that the application was intended to prevent.
How we structure a capped-fee proposal
After reviewing the service model and current readiness, we define assumptions, deliverables, client inputs, dependencies, third-party work, milestones, exclusions and change triggers. The professional fee is separated from the GEL 5,000 official registration fee, supervisory capital and third-party costs. If the client later changes a material assumption—such as adding custody, a trading platform, cash branches or stablecoin issuance—we identify the regulatory, capital and fee effect before starting the additional work.
Applicable legislation and regulatory materials
Our registration work is mapped to the current Georgian legal framework and the applicant’s actual operating model. Legal texts reproduced in the CryptoLicense.ge legislation library link to the official Matsne source from the relevant legal-text page.